Effect of compromise agreement

(a)(1) A compromise agreement relates to the entire liability of the taxpayer with respect to the period and type of tax for which the offer in compromise is submitted, and all questions of such liability are conclusively settled thereby.

(2) Neither the Secretary of the Department of Finance and Administration nor the taxpayer shall, upon acceptance of an offer in compromise, be permitted to revise the agreement except by reason of the following:

(A) Falsification or concealment of facts or assets by the taxpayer; or

(B) Mutual mistake of a material fact concerning the basis for an offer in compromise.

(b) Acceptance of an offer in compromise of a civil liability does not constitute a settlement of a criminal liability concerning the tax period in question.